The short answer
- Master file Part A has no threshold: every Indian constituent entity of an international group files it, even a small one.
- Master file Part B applies when group revenue exceeds INR 500 crore and the Indian entity's international transactions exceed INR 50 crore (INR 10 crore for intangibles).
- The country-by-country report applies when group revenue exceeds INR 6,400 crore. It is due 12 months after year end.
- From 1 April 2026 the forms are renumbered: 3CEAA to 3CEAE became Forms 56 to 60.
- A Singapore subsidiary of an Indian group does not file CbCR in Singapore. Pillar Two is different: large groups may owe Singapore top-up tax.
Why Indian groups struggle with this
These filings sit between the tax team, the transfer pricing adviser and the group reporting team, and each assumes another owns them. Part A of the master file catches small groups who think transfer pricing does not apply to them. Flipped structures, with a Singapore top company and an Indian operating subsidiary, catch the most people: the Indian subsidiary is a constituent entity of an international group from day one.
India: the forms and thresholds
| New form (from 1 April 2026) | Old form | What it is | Who and when |
|---|---|---|---|
| Form 56 | 3CEAA | Master file, Parts A and B | Part A: every Indian constituent entity. Part B: group revenue above INR 500 crore and international transactions above INR 50 crore (or intangibles above INR 10 crore). Due with the income tax return |
| Form 57 | 3CEAB | Designating one Indian entity to file the master file | At least 30 days before the master file due date |
| Form 58 | 3CEAC | Intimation by Indian entities of a foreign-parented group about who files CbCR | At least two months before the CbCR due date |
| Form 59 | 3CEAD | Country-by-country report | Indian parent or alternate reporting entity, where group revenue exceeds INR 6,400 crore. Within 12 months of year end |
| Form 60 | 3CEAE | Designating one Indian entity for CbCR where there are several | At least 30 days before the CbCR due date |
Penalties to know
- Not furnishing the master file: INR 5 lakh.
- Late CbCR: INR 5,000 a day for the first month, INR 15,000 a day after that, and INR 50,000 a day after a penalty order.
- Inaccurate CbCR: INR 5 lakh, on top of any delay penalty.
Singapore: what the subsidiary must do
- CbCR: Singapore requires CbCR only from Singapore-headquartered groups with consolidated revenue of at least S$1,125 million. A Singapore subsidiary of a foreign (including Indian) group has no CbCR filing or notification requirement in Singapore.
- Transfer pricing documentation: still applies at entity level when the Singapore thresholds are crossed. See transfer pricing between India and Singapore.
Pillar Two: the newer risk
Singapore applies a domestic top-up tax and a multinational enterprise top-up tax for financial years starting on or after 1 January 2025. Groups with consolidated revenue of at least EUR 750 million in two of the four preceding years, with an entity in Singapore, must register.
- Registration: within six months after the end of the group's first financial year in scope. For a group whose first such year ended 31 December 2025, that was 30 June 2026.
- Returns: generally 15 months after year end, 18 months for the first year.
- Indian groups: a Singapore subsidiary of a group above the threshold is a constituent entity in Singapore, so it can be in scope for domestic top-up tax if its effective rate is low. Check whether your Singapore entities enjoy incentives that bring the rate below 15%.
Checklist for the group finance team
- Confirm the group's consolidated revenue against INR 500 crore, INR 6,400 crore and EUR 750 million
- List every Indian constituent entity and its Part A obligation
- Decide who files: parent, designated entity, or alternate reporting entity
- Diarise Forms 56 to 60 under the new numbers
- Check Pillar Two registration for every Singapore entity
- Reconcile CbCR numbers to the consolidated accounts before filing
Questions people ask
Does every Indian group entity file a master file?
Part A, yes: every Indian constituent entity of an international group files it, with no threshold. Part B applies above INR 500 crore group revenue and INR 50 crore of international transactions.
What replaced Forms 3CEAA to 3CEAE?
Forms 56 to 60 under the Income-tax Act, 2025, from 1 April 2026. Form 59 is the country-by-country report.
Does a Singapore subsidiary of an Indian group file CbCR in Singapore?
No. Singapore CbCR applies only to Singapore-headquartered groups with revenue of at least S$1,125 million. Pillar Two registration may still apply to large groups.
Talk it through with an adviser
Tell us your structure and deadlines. We reply with what applies to you and a fixed-fee proposal.
Sources
- Treelife: Master file and CbCR in India, old and new forms (secondary source)
- CAclubindia: Forms 56 to 60 under the Income-tax Act, 2025 (secondary source)
- IRAS: Country-by-country reporting
- Forvis Mazars: CbCR for Singapore-headquartered groups (secondary source)
- IRAS: Registration for MTT and DTT (Pillar Two)
- ASEAN Briefing: Singapore Pillar Two registration (secondary source)
General information only, last reviewed 1 November 2026. It is not advice for your situation. Laws and practice change, and the official sources linked above prevail. Speak to a qualified adviser before you act. Northwise does not file with Indian authorities; India-side work is done by independent licensed firms.
